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GIFTS OF MONEY AND PROPERTYbusiness purpose and disregarded the debt form of the transaction for tax purposes.Did the company contribute the $19,976,934 to the college? The answer isno, because no payments have yet been made to the institution (even accrualbasis donors must actually make payments on a timely basis). 95 Thus, the issue isone of timing, with the bond documentation reflecting a pledge. It would seemthat, once made, any payments to the school would be deductible as a charitablegift (assuming all other requirements were met). After all, the court found thatthe company’s motive underlying the transaction was not a business purpose,but was one of substantial economic disinterest.When the charitable organization involved is a private foundation, 96 thematter of a charitable pledge can be more complicated if the pledger is a disqualifiedperson 97 with respect to the foundation. The principal difficulty iswith the rules concerning self-dealing. 98 The making of a pledge by a disqualifiedperson to a private foundation, in and of itself, is not an act of self-dealing. 99Likewise, the making of a pledge that, when it ripens into a contribution, requiresa facility or organization to be named after the disqualified person, is not an act ofself-dealing, because the benefit to the disqualified person is incidental and tenuous.100 Under some circumstances, however, the satisfaction of a pledge by a disqualifiedperson to a private foundation can be self-dealing. In one instance, forexample, a private foundation paid the dues of a disqualified person to a church,thereby enabling him to maintain his membership in and otherwise participate inthe religious activities of the congregation. The dues payment was ruled to constituteself-dealing, with the IRS concluding that the private foundation’s paymentof the dues “result[ed] in a direct economic benefit to the disqualified personbecause that person would have been expected to pay the membership dues hadthey not been paid by the foundation.” 10195 IRC § 170(a)(2).96 See § 3.4.97 Id., note 404.98 IRC § 4941 (see Private Foundations Ch. 5).99 Reg. § 53.4941(d)-2(c)(3).100 Reg. §§ 53.4941(d)-2(f)(2), 53.4941(d)-2(f)(4), Example (4).101 Rev. Rul. 77–160, 1977-1 C.B. 351, 352. 144